SEAWAY GLOBAL

Anti-Slavery and Human Trafficking Policy for Seaway Global Co., Ltd.

1. PURPOSE

Seaway Global Co., Ltd. is committed to ethical and responsible business conduct. We strongly oppose all forms of modern slavery, including forced labor, child labor, and human trafficking. This policy outlines our approach to identifying, preventing, and addressing such practices in our business and throughout our supply chains.

2. SCOPE & Zero Tolerance Statement

2.1 This policy applies to all employees, officers, temporary workers, contractors, consultants, and any third-party individuals or organizations acting on behalf of Seaway Global, as well as all suppliers, subcontractors, and business partners globally.

2.2 As a global supplier of marine chemicals and lubricants, Seaway Global maintains business relationships with numerous overseas partners. We hereby declare a zero-tolerance approach to all forms of modern slavery and human trafficking, not only within our own operations but across all tiers of our supply chain. We expect the same commitment from all those we do business with.

2.3 Seaway Global is firmly committed to respecting and promoting fundamental human rights throughout all aspects of its operations. We adhere to internationally recognized standards, including: · The Universal Declaration of Human Rights · The OECD Guidelines for Multinational Enterprises · The UN Guiding Principles on Business and Human Rights This policy applies to all officers and employees of Seaway Global, who are expected to uphold these principles in their daily work and decision-making processes.Furthermore, Seaway Global expects all business partners, suppliers, and other entities within its supply chain to comply with human rights standards that are equivalent to those outlined in this policy. We believe that respecting human rights is not only a legal obligation but a core element of responsible business conduct.

2.4 Modern slavery constitutes a criminal offense in many jurisdictions in which the Company conducts business. Any involvement in such practices may result in severe legal consequences, including criminal prosecution, for both the Company and the individuals directly or indirectly involved.
All employees are required to comply fully with this policy. No individual within the Company, regardless of their position or authority, is permitted to issue any directive, instruction, or order that contravenes the provisions of this policy.

2.5 This Anti-Slavery and Human Trafficking Policy has been designed to provide practical guidance on the following: · The definition and scope of slavery and human trafficking prohibition · The reasons why compliance with this policy is mandatory · Practical steps for ensuring adherence to this policy in day-to-day operations

2.6 Please contact the Human Resources Operations Team and the Legal Compliance Support Team for appropriate guidance regarding this policy. Any employee who becomes aware of a violation of this policy during the course of business must report it to the Company immediately. For guidance and reporting, please refer to the details provided in Section 4.2 of this policy.

3. WHAT IS MODERN SLAVERY?

3.1 Modern slavery refers to situations where individuals are forced, coerced, or exploited in ways that violate their basic human rights. It is a term used to describe various forms of severe exploitation and control that involve the denial of personal freedom and autonomy. While slavery in the traditional sense is illegal worldwide, modern slavery continues to exist, often in hidden or less visible forms.

3.2 The Company is committed to ensure slavery and human trafficking is not present not only in any part of its business but also any of its supply chains. The Company’s supply chain includes suppliers of raw materials and machinery, subcontractors, security, cleaning, catering contractors, IT providers, transport/logistics contractors, outsourced labor suppliers, search firms, suppliers of office equipment and joint venture partners. Here are some key elements of modern slavery:

A. Forced Labor

People are compelled to work under threat of violence, punishment, or other forms of coercion, often with little or no pay, and in conditions of extreme exploitation.

(a)All work must be conducted on a voluntary basis, and not under threat of any penalty orsanctions.
(b)Employees are not required to make deposits, provide financial guarantees, or make payments to employers, staffing agencies, or recruitment firms as a condition of obtaining employment related to the Company.
(c)Original copies of identity documents (such as passports, identity cards, etc.) must not be retained for the purposes of forced labor.
(d)Bonded or indentured labor is strictly prohibited. Workers have the right to terminate their employment upon providing reasonable notice and are entitled to receive all earned wages. We must respect the right of workers to leave the workplace after their shift.
(e)There must be no forced, bonded or involuntary prison labor.

B. Child labor

The use of children for work that deprives them of their childhood, education, and well-being, often in dangerous or harmful conditions.

(a) Must not employ workers who are younger than
(1) the legal minimum age for employment applicable in the relevant jurisdiction

(2) or the age of completion of compulsory education.
(b) Must implement robust age verification checks at all times.
(c) Child labor must not be recruited or exploited in any form. If a child is found working for the Company or its suppliers, a remediation plan must be implemented to prioritize the child’s best interests and ensure access to appropriate education until they are no longer a child.
(d) Young workers must be protected from hazardous work and night shifts, and must be guaranteed at least the minimum wage. Working hours and overtime limits must be set with special consideration for their age.

C. Human Trafficking

The illegal trade of people for the purposes of exploitation. This may involve transporting individuals across borders or within countries for purposes such as sexual exploitation, forced labor, or domestic servitude.

(a) The Company must not engage in recruiting, harboring, transporting, providing, or obtaining any person for forced labor or commercial sex through fraud, coercion, or deception.

D. Sexual Exploitation

Individuals are forced into prostitution or other forms of sexual exploitation through coercion, threats, or manipulation.

E. Domestic Servitude

Individuals, often women and children, are forced to work in households, performing tasks such as cleaning, cooking, and caring for children, with no freedom, pay, or rights, and often under abusive conditions.

4. Supply Chain Due Diligence and Risk Management

To ensure appropriate measures are in place to prevent modern slavery and human trafficking within the Company’s supply chains, the Company shall: 1. Conduct risk assessments to identify areas of its business and suppliers most at risk, enabling targeted action. 2. Engage with suppliers to communicate this Anti-Slavery and Human Trafficking Policy and assess their measures to prevent modern slavery. 3. Include contractual provisions requiring suppliers to comply with this policy and acknowledge the Company’s right to terminate the relationship in case of non-compliance.

5. CONSEQUENCES OF BREACH

5.1 If the Company is investigated for a potential breach of modern slavery laws or equivalent regulations in relevant jurisdictions, the following consequences may arise: (a) Publicity and Regulatory Scrutiny: Such investigations may lead to negative publicity and increased regulatory oversight in the future. (b) Claims for Damages: In certain jurisdictions (e.g., the UK), third parties suffering losses due to a breach may initiate legal proceedings for damages and seek interim relief, such as injunctions to halt ongoing violations. (c) Costs of defending an investigation: in addition to legal costs, investigations cause significant disruption to business and place considerable demands on management time. (d) Blacklisting/Event of Default (EOD): A significant additional risk of breaching modern slavery laws is the potential blacklisting of the Company from publicly tendered work, as well as the risk of being prohibited from bidding on MDB (Multilateral Development Bank) financed projects for a specified period. The Company may also face EOD risks in ongoing projects.

5.2 If an issue is identified with a supplier, the Company will collaborate with them to develop a corrective action plan and resolve all violations within an agreed-upon timeframe. The Company reserves the right to terminate its relationship with any individual or organization in its supply chain in the event of a breach of this policy.

5.3 The Company takes this policy very seriously, and violations may result in disciplinary action, including, but not limited to, termination of employment. The Company reserves the right to determine the appropriate response to any violation of this policy, in accordance with all applicable local laws and the Company's HR regulations.

6. CONSULTATION, REPORT AND WISTLEBLOWING PROTECTION

6.1 If you have any concerns regarding an issue that you believe or suspect may violate any law or breach this policy, you must report it to the Company as soon as possible. All employees are also encouraged to raise concerns about any instance of modern slavery within any part of the Company's supply chains at the earliest possible stage.

6.2 All reports will be kept confidential and will be handled appropriately. You will not face retribution or retaliation for making a complaint in good faith. The Company is committed to ensuring that no individual suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery, in any form, is or may be occurring within any part of its business or supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or any other adverse action related to raising a concern. If any employee believes they have suffered such treatment, they should immediately report it in accordance with the Whistleblowing Policy and Procedure.

7. Grievance Handling and Employee Training

7.1 Seaway Global operates various communication channels for different stakeholders. (1) For the supply chain, feedback can be submitted via the company’s website and email. (2) Regarding community members, the company operates a grievance handling system at the community level, while feedback can also be submitted through the website and email.

8. Review and Continuous Improvement

This policy is reviewed at least annually to ensure its effectiveness and relevance. We remain committed to continuous improvement in upholding human rights and eradicating modern slavery within our operations and across our global supply chain.